ML20116E795
| ML20116E795 | |
| Person / Time | |
|---|---|
| Site: | Hatch  |
| Issue date: | 04/16/1985 |
| From: | Gucwa L GEORGIA POWER CO. |
| To: | Stolz J Office of Nuclear Reactor Regulation |
| References | |
| 1444N, NED-85-102, TAC-57450, TAC-57451, NUDOCS 8504300418 | |
| Download: ML20116E795 (3) | |
Text
_ __ __- _____ __-___________________-_____
Georgra Power Company 333 Piedmont Asenue Atlanta, Georgia 30308 F
Telephor'e 404 526 652d
- Makg Address:
Post Otf.ce Box 4545 A!!anta. Georgia 30302 Georgia Power Ma a uclear Engrneering and Chief Nuclear Engerwxt ED-85-102 1444N April 16, 1985 Director of Nuclear Reactor Regulation Attention: Mr. John F. Stolz, Chief Operating Reactors Branch No. 4 Division of Licensing U. S. Nuclear Regulatory Commission Washington, D. C.
20555 NRC DOCKETS 50-321, 50-366 OPERATING LICENSES DPR-57, NPF-5 EDWIN I. HATCH NUCLEAR PLANT UNITS 1, 2 RESPONSE TO ALLEGATION CONCERNING NON-USE OF AUTHORIztu NUCLEAR INSPECTOR Gentlemen:
By letter dated January 28, 1985, NRC advised Georgia Power Company (GPC) that it had received a statement alleging that GPC is not using an authorized nuclear inspector (ANI) for all weld repair activities.
GPC hereby provides the following information in response to that allegation.
Repairs to the pressure retaining boundary of ASME Class 1, 2, and 3 (equivalent) components are performed in accordance with IWA-4000 (or IWB-4000, where appropriate for certain Class 1 components only) by utilizing GPC-approved procedures which generally comply with the code applicable to the construction of the component. While an ANI is not always used, particularly during maintenance repairs (e.g., valves), an ANI has been used on a case-by-case basis dependent upon the nature of the repair / replacement.
To the best of our knowledge, this approach is nct unique in the industry.
Such occasions where an ANI has been used includes replacement of the RWCU penetration
- piping, off-gas piping repair / replacement, recirculation piping replacement, and recent weld overlay repairs.
CPC Quality Control and Quality Assurance provide essentially the same function as the ANI by auditing all inspections, repairs, procedures, etc.
While no formal " repair or replacement program" document exists for every repair / replacement performed, all elements that f
[BR*'288R5%lgi li,p
o GeorgiaPower A Director of Nuclear Reactor Regulation Attent'.on:
Mr.. John F. Stolz,. Chief Operating Reactors Branch No. 4 April 16, 1985 Page Two would be included in such a document do exist and are subject to audit by NRC inspection personnel during repair / replacement activities.
These elements include, but are not limited to, nondestructive examination (NDE) procedures, welding procedures and welder qualifications, hydrostatic tests, etc.
GPC believes it's approach to welded repairs / replacements meets the objective of the Code (i.e.,
work is performed to high standards and verified to be proper) and provides assurance of safe repairs equal to the assurance provided by the use of an ANI in all Section XI repair work.
We request, therefore, that the NRC concur in our use of-company QA/QC inspectors for. routine repairs supplemented on a case-by-case basis by a independent ANI.
While the allegation has raised a question of degree of Code compliance, public health and safety and continued safe plant operations have not been adversely affected by the use of an ANI on a selected basis.
Should you have any further questions in this regard, please contact this office.
Sincerely yours,
- f. r n L. T. Gucwa JAE/mb xc:
J. T. Beckham, Jr.
H. C. Nix, Jr.
J. N. Grace (MIC-Region II)
Senior Resident Inspector
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